Commission Implementing Regulation (EU) 2025/23

Cover Regulation

COMMISSION IMPLEMENTING REGULATION (EU) 2025/23

of 19 December 2024

laying down rules for the application of Regulation (EU) 2018/1139 of the European Parliament and of the Council, as regards requirements for the oversight of ground handling services and organisations providing them

Regulation (EU) 2025/23

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91⁵, and in particular
Article 62(14) point (d), Article 62(15) points (a), (b) and (c), and Article 72(5) thereof,

Whereas:

(1)Regulation (EU) 2018/1139 establishes the essential requirements for the safe provision of ground handling services and organisations providing them at aerodromes within the scope of that Regulation, as well as provisions for oversight by national competent authorities of those organisations and the ground handling services provided at the Union aerodromes within the scope of that Regulation.

(2)To ensure a high level of civil aviation safety in the Union, and in line with the principle of subsidiarity, this Regulation should reflect the state of the art and best practices in the field of ground handling. It should also take into account the applicable International Civil Aviation Organization Standards and Recommended Practices and worldwide ground handling operation experience, as well as scientific and technical progress in the ground handling domain. Furthermore, in order to ensure an adequate amount of oversight of organisations providing ground handling services, the rules laid down in this Regulations should be proportionate, adjusted to the safety risk of ground handling activities and safety performance of the ground handling organisations and should provide for the necessary flexibility for customised compliance.

(3)The requirements laid down in this Regulation should ensure that Member States conduct a harmonised and consistent oversight of organisations providing ground handling services at Union aerodromes. Therefore, this Regulation should provide the framework for the development and implementation by competent authorities of a management system to encompass the necessary processes, training and qualification of personnel, and procedures for oversight and particularly cooperative oversight of ground handling organisations.

(4)To ensure that the oversight of declaring ground handling organisations is performed in a competent and correct manner and that the results of oversight are properly utilised to improve the safety of the overseen organisations, national competent authorities should ensure that the inspectors conducting oversight are adequately trained and qualified, and have appropriate skills and experience to assess the safety performance of the ground handling organisations under their oversight responsibilities.

(5)To enable efficient use of resources of competent authorities when performing oversight and encourage the harmonisation of ground handling operational processes and procedures by the voluntary use of industry standards, this Regulation should enable Member States to assess together the compliance of the industry standards with Annexes I and II to Commission Delegated Regulation (EU) 2025/20⁶.

(6)The oversight activities covering the verification of compliance of ground handling organisations with all the applicable requirements and in accordance with the declaration submitted should be applied in a consistent manner and spanning over the period established in this Regulation. To achieve this, competent authorities should develop and implement an oversight programme to ensure the scope of the oversight is fully covered as planned.

(7)To ensure the implementation of a risk-based oversight, the oversight programme should be partly based on safety data collected from ground handling organisations, which would support competent authorities in having a complete picture of the level of safety for each ground handling organisation subject to oversight. The safety reports should ensure reliable and sufficient information to enable accurate safety analysis.

(8)To ensure that the reporting obligations of ground handling organisations contribute to the improvement of safety in ground handling operations, this Regulation should establish a framework for competent authorities to provide direct and consistent feedback on the reported ground handling events directly to the ground handling organisations and this should be enabled, among others, through the oversight process.

(9)Regulatory measures should prioritise cooperation between national competent authorities in overseeing organisations providing ground handling services at aerodromes located in more than one Member State, to improve resource utilisation and avoid duplication of work and oversight. The national competent authorities involved in the oversight of organisations providing ground handling services at aerodromes located in more than one Member State should share the information necessary for an efficient and harmonised oversight. Good coordination of the entire process and sharing of oversight tasks between the Member States concerned are crucial in ensuring an efficient cooperative oversight. In this sense, national competent authorities involved in the cooperative oversight process should rely on clear rules defining their tasks and have the right tools so that they can share among themselves the results of the oversight activities performed at the aerodromes under their oversight and at the ground handling organisation’s principal place of business, from where it exercises control and applies the management system across all its stations.

(10)The measures provided for in this Regulation are based on Opinion No 01/2024⁷ issued by the European Union Aviation Safety Agency (‘the Agency’) in accordance with Article 75(2),
points (b) and (c), and Article 76(1) of Regulation (EU) 2018/1139.

(11)It is necessary to provide sufficient time for the competent authorities to implement the new regulatory framework after the entry into force of this Regulation. Therefore, the application of this Regulation should be deferred to 27 March 2028.

(12)The requirements laid down in this Regulation are in accordance with the opinion of the Committee for the application of common safety rules in the field of civil aviation established by Article 127 of Regulation (EU) 2018/1139,

HAS ADOPTED THIS REGULATION:

Regulation (EU) 2025/23

This Regulation lays down detailed rules on the allocation of responsibilities of national competent authorities responsible for the oversight of ground handling services and organisations providing such services, rules on exchange of information, qualification of personnel and administration and management systems of those competent authorities.

Regulation (EU) 2025/23

For the purpose of this Regulation, the following definitions shall apply:

(1)‘cooperative oversight’ means a coordinated oversight process that involves more than one competent authority to oversee an organisation providing ground handling services at aerodromes that are under the jurisdiction of more than one competent authority or in more than one Member State; whereas the competent authorities determine their individual tasks, share relevant data and information for the oversight, promote cooperation to ensure a uniform oversight and efficient use of resources by, inter alia, avoiding duplications of tasks, audits and inspections;

(2)‘audit’ means a systematic, independent and documented process for obtaining evidence and evaluating it objectively to determine the extent to which requirements are complied with; whereas audits may include inspections;

(3)‘inspection’ means, in the context of compliance monitoring and oversight, an independent and documented conformity evaluation by observation and judgement accompanied, as appropriate, by measurements, testing or gauging, in order to verify compliance with applicable requirements; whereas an inspection may be part of an audit, but may also be conducted outside the normal audit plan, in particular, to verify the closure of a certain finding.

Regulation (EU) 2025/23

1.Each Member State shall designate one or more competent authorities within that Member State, with the necessary powers and responsibilities for the oversight and enforcement tasks regarding ground handling organisations operating at the aerodromes within the scope of Regulation (EU) 2018/1139.

2.The national competent authorities shall have the following obligations, which are detailed further in the Annex to this Regulation:

(a)to receive declarations from organisations that perform ground handling services at the aerodromes that are under their jurisdiction;

(b)to conduct oversight of those ground handling organisations;

(c)to ensure the personnel assigned to perform ground handling oversight are appropriately trained, qualified and competent and their competence is maintained;

(d)to contribute to the implementation of an effective cooperative oversight;

(e)to take or initiate enforcement measures as appropriate.

3.Member States shall ensure that the competent authorities have the necessary capabilities and resources to fulfil their responsibilities under this Regulation.

4.Member States shall ensure that competent authorities exercise their powers impartially and transparently.

Regulation (EU) 2025/23

1.Where a Member State designates more than one competent authority, it shall set out the responsibilities and geographic scope of competence of each competent authority.

Coordination shall be established between those authorities to ensure effective oversight of all ground handling activities and organisations performing them within their respective remits.

2.Member States shall ensure that the competent authorities’ personnel do not perform oversight activities where this could result directly or indirectly in a conflict of interest.

3.Personnel authorised by the competent authority to carry out oversight activities shall be empowered to perform the following tasks:

(a)examine the records, data, procedures and any other material relevant to the execution of the oversight task;

(b)take away copies of or extracts from such records, data, procedures and other material;

(c)ask for an oral explanation on-site when necessary;

(d)enter relevant premises, operating sites or other relevant areas and means of transport;

(e)perform audits, investigations, tests, exercises, assessments, inspections; and

(f)take or initiate enforcement measures as appropriate.

Where necessary, Member States shall empower the personnel to carry out additional tasks for the purpose of oversight activities.

4.Where a ground handling organisation falls within the scope of Article 2(1), point (c), of Commission Delegated Regulation (EU) 2022/1645⁸, and the Member State concerned has designated an independent and autonomous entity to fulfil the assigned role and responsibilities of the competent authority responsible for overseeing compliance with Delegated Regulation (EU) 2022/1645, coordination measures shall be established between that entity and the national competent authority designated in accordance with this Regulation, to ensure effective oversight of all the requirements to be met by the ground handling organisation.

5.The Member States shall develop and implement enforcement measures as specified in
Article 62(2) points (d) and (e), of Regulation (EU) 2018/1139.

Regulation (EU) 2025/23

The Agency shall facilitate the effective implementation of the cooperative oversight requirements by the Member States, to enable secure access and exchange of relevant information and documentation among competent authorities, necessary to exercise their tasks related to oversight and enforcement pursuant to this Regulation.

Regulation (EU) 2025/23

By way of derogation from point ARGH.OVS.305(c), competent authorities shall perform at least one comprehensive oversight of all declaring organisations in their Member State by 27 March 2028 + 5 years = 27 March 2033 at the latest.

The competent authority shall take into account the prior operational experience of an organisation when developing its oversight plan.

Regulation (EU) 2025/23

1.This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

2.It shall apply from 27 March 2028.

3.The following points shall apply from 27 March 2031:

(a)point ARGH.GEN.125(c);

(b)point ARGH.GEN.136;

(c)point ARGH.MGM.200(e);

(d)point ARGH.MGM.205(e);

(e)point ARGH.MGM.211;

(f)point ARGH.OVS.300(f).

Regulation (EU) 2025/23

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 19 December 2024.

For the Commission

The President

Ursula VON DER LEYEN

ANNEX — AUTHORITY REQUIREMENTS – GROUND HANDLING (PART-ARGH)

SUBPART GEN — GENERAL REQUIREMENTS

Regulation (EU) 2025/23

This Annex establishes requirements for the competent authorities and for their responsibilities referred to in Articles 3(1) and 4 of this Regulation to conduct oversight of the ground handling organisations and the ground handling services that they provide in accordance with Delegated Regulation (EU) 2025/20.

Regulation (EU) 2025/23

(a)The competent authority responsible for the oversight of organisations providing ground handling services at an aerodrome within the scope of Regulation (EU) 2018/1139 shall be the authority designated by the Member State where the aerodrome is located.

(b)Without affecting point (a), the competent authority responsible for receiving the declaration from a single ground handling organisation business grouping or a self-handling aircraft operator that has its principal place of business in a Member State and provides ground handling services in more than one Member State shall be the authority designated by the Member State where the organisation has its principal place of business.

That declaration shall be considered to have been submitted to all competent authorities concerned if both the following conditions are met:

(1)it includes information on the ground handling services provided at all the aerodromes within the scope of Regulation (EU) 2018/1139 in all the Member States where the ground handling organisation provides services;

(2)it reaches out to all the Member States concerned through the repository of information established in accordance with Article 74 of Regulation (EU) 2018/1139.

(c)Once submitted, the declaration is valid and recognised in all Member States without further requirements or evaluation, in accordance with Article 67(1) of Regulation (EU) 2018/1139.

(d)The competent authority responsible for the oversight of organisations referred to in point (b) shall be the authority designated by the Member State where the aerodrome is located. The sharing of tasks among the competent authorities concerned for the oversight of those organisations shall be done in accordance with point ARGH.OVS.330.

ED Decision 2025/006/R

COMPETENT AUTHORITY RESPONSIBLE FOR RECEIVING DECLARATIONS

(a)The competent authority should make publicly available its contact information for the purpose of receiving declarations.

(b)The competent authority receiving a declaration from a single ground handling (GH) organisation business grouping or a self-handling aircraft operator that has its principal place of business (PPoB) in the Member State of that authority and provides GH services in more than one Member State should ensure that all the other competent authorities have received that declaration.

Regulation (EU) 2025/23

The competent authority shall provide the relevant legal acts, standards, rules, technical publications and related documents, as well as guidance material to its personnel in order to allow them to perform their tasks and to discharge their responsibilities.

ED Decision 2025/006/R

AVAILABILITY OF DOCUMENTATION

It is recommended that legislative acts, standards, rules, technical publications, guidelines and other similar documents be made available, in a timely manner, to the competent authority’s personnel in various ways and formats.

Regulation (EU) 2025/23

The Agency shall develop acceptable means of compliance (AMC) that may be used to establish compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.

ED Decision 2025/006/R

ALTERNATIVE MEANS OF COMPLIANCE

(a)The competent authority may use alternative means of compliance (AltMoC) to establish compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.

(b)The competent authority should establish a system to consistently check that the AltMoC used by itself or by the GH organisations under its oversight comply with Regulation (EU) 2018/1139 and its delegated and implementing acts. That system should include procedures to limit, revoke or amend AltMoC if the competent authority finds that these do not comply with Regulation (EU) 2018/1139 and its delegated and implementing acts.

(c)The competent authority should evaluate the AltMoC proposed by GH organisations in accordance with point ORGH.GEN.120 of Commission Delegated Regulation (EU) 2025/20, by analysing the documentation provided and, if necessary, conducting an inspection of the organisations. When the competent authority finds that the AltMoC proposed by a GH organisation are in accordance with Regulation (EU) 2018/1139 and its delegated and implementing acts, it should inform the Agency of their content, including copies of the relevant documentation.

(d)If the competent authority itself uses AltMoC to achieve compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts, it should:

(1)conduct a safety risk assessment of the AltMoC, which should demonstrate that compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts is met;

(2)make the AltMoC available to the GH organisations under its oversight if those AltMoC are intended for use by GH organisations;

(3)notify the Agency without undue delay; and

(4)provide the Agency with:

(i)a full description of the AltMoC, including any revision to manuals or procedures that may be relevant; and

(ii)the safety risk assessment referred to in point (1).

(e)AltMoC used by a competent authority or by a GH organisation under its oversight may be used by other competent authorities or GH organisations. However, they should be processed again in accordance with point (c) or (d), as applicable.

Regulation (EU) 2025/23

(a)Where the competent authority has become aware of any significant problems with the implementation, by a ground handling organisation, of Regulation (EU) 2018/1139 and its delegated and implementing acts, it shall notify the Agency thereof without undue delay, and in any case within 30 days from the time it has become aware of those problems.

(b)Without affecting Regulation (EU) No 376/2014 of the European Parliament and of the Council⁹ and its delegated and implementing acts, the competent authority shall provide the Agency, as soon as possible, with safety-significant information stemming from occurrence reports stored in the national database pursuant to Article 6(6) of Regulation (EU) No 376/2014.

(c)The competent authority shall provide the Agency, as soon as possible, with safety-significant information stemming from the information security reports it has received pursuant to
point IS.D.OR.230 of the Annex to Delegated Regulation (EU) 2022/1645.

[point (c) applicable from 27 March 2031 — Regulation (EU) 2025/23]

ED Decision 2025/006/R

EXCHANGE OF SAFETY-SIGNIFICANT INFORMATION WITH THE AGENCY

Each competent authority should appoint a coordinator to act as the contact point or focal point for the exchange of safety-significant information between the competent authority and the Agency. This function may be assigned within the competent authority to a person or a group of persons already performing such tasks in other aviation domains.

ED Decision 2025/006/R

MEANING OF ‘SAFETY-SIGNIFICANT INFORMATION STEMMING FROM OCCURRENCE REPORTS’

‘Safety-significant information stemming from occurrence reports’ means a safety analysis summarising individual occurrence data and providing an in-depth analysis of a safety issue, which may be relevant to the Agency’s safety-related action planning.

More information can be found in the Guidance Material to Regulation (EU) No 376/2014¹⁰, specifically Section 4 ‘Competent authorities’ and in particular Section 4.3 ‘How is the information shared among the competent authorities?’.

ED Decision 2025/006/R

RECOMMENDED CONTENT FOR CONCLUSIVE SAFETY ANALYSES

A conclusive safety analysis contains the following elements:

(a)a detailed description of the safety issue, including the scenarios in which the safety issue may occur;

(b)an indication of the stakeholders affected by the safety issue, including types of operations and organisations;

and, as appropriate:

(c)a safety risk assessment establishing the severity and probability of all the possible consequences of the safety issue;

(d)information about the safety measures that the aviation system has in place to prevent the likely consequences of the safety issue from occurring or to reduce those consequences;

(e)any mitigating actions already in place or developed to address the safety issue;

(f)recommendations for future actions to control the risk; and

(g)any other element that the competent authority considers essential for the Agency to properly assess the safety issue.

Regulation (EU) 2025/23

(a)Without affecting Regulation (EU) No 376/2014 and its delegated and implementing acts, the competent authority shall implement a system to collect, analyse and disseminate safety information.

(b)The Agency shall implement a system to analyse any safety-relevant information received and, without undue delay, provide the competent authority of the Member States and the Commission with any information, including recommendations or corrective actions to be taken, necessary for them to react in a timely manner to a safety problem involving organisations responsible for the provision of ground handling services subject to Regulation (EU) 2018/1139 and its delegated and implementing acts.

(c)Upon receiving the information referred to in points (a) and (b), the competent authority shall take adequate measures to address the safety problem.

(d)The competent authority shall immediately transmit the measures taken in accordance with point (c) to the ground handling organisation, which shall comply with them under
Regulation (EU) 2018/1139 and its delegated and implementing acts. The competent authority shall also notify those measures to the Agency and, when combined action is required, to the other competent authorities concerned.

(e)If relevant, the measures notified to a ground handling organisation shall also be notified to the aerodrome operator where the ground handling organisation provides the ground handling services subject to those measures.

ED Decision 2025/006/R

INFORMATION FOR THE AIRCRAFT OPERATORS CONCERNED

The competent authority should advise the GH organisation to immediately inform the aircraft operators to which it provides services and that are affected by the safety issue of the implementation of the safety measures mandated by the competent authority or EASA.

Regulation (EU) 2025/23

(a)The competent authority shall implement a system for the collection, analysis, and dissemination of information related to information security incidents and vulnerabilities with a potential impact on aviation safety that are reported by ground handling organisations. This shall be done in coordination with any other relevant authorities responsible for information security or cybersecurity within the Member State concerned to increase the coordination and compatibility of reporting schemes.

(b)The Agency shall implement a system for the analysis of any relevant safety-significant information received pursuant to point ARGH.GEN.125(c), and without undue delay provide the Member States and the Commission with any information, including recommendations or corrective actions to be taken, necessary for them to react in a timely manner to an information security incident or vulnerability with a potential impact on aviation safety involving products, equipment, persons or organisations subject to Regulation (EU) 2018/1139 and its delegated and implementing acts.

(c)Upon receiving the information referred to in points (a) and (b), the competent authority shall take adequate measures to address the potential impact of the information security incident or vulnerability on aviation safety.

(d)Measures taken in accordance with point (c) shall immediately be notified to all persons or organisations that shall comply with them under Regulation (EU) 2018/1139 and its delegated and implementing acts. The competent authority shall also notify those measures to the Agency and, when combined action is required, the competent authorities of the other Member States concerned.

[point ARGH.GEN.136 applicable from 27 March 2031 — Regulation (EU) 2025/23]

SUBPART MGM — MANAGEMENT

Regulation (EU) 2025/23

(a)The competent authority shall establish, implement and maintain a management system that includes all the following elements:

(1)documented policies and procedures to describe its organisation, means and methods to achieve compliance of the competent authority with Regulation (EU) 2018/1139 and its delegated and implementing acts, which shall be kept up to date and serve as the basic working documents within that competent authority for all related tasks;

(2)sufficient personnel, including inspectors, to perform its tasks and discharge its responsibilities;

(3)adequate facilities and office accommodation to perform the allocated tasks;

(4)a function to monitor the compliance of the management system with the relevant requirements and adequacy of the procedures including the establishment of an internal audit process and a safety risk management process;

(5)a person or group of persons, ultimately responsible to the senior management of the competent authority for the compliance monitoring function.

(b)Regarding the personnel referred to in point (a)(2), the competent authority shall ensure the following:

(1)the personnel shall have relevant aviation knowledge and experience and shall be adequately trained and qualified to perform the allocated tasks;

(2)the inspectors shall receive initial training, on-the-job training, and recurrent training to ensure their continued competence, depending on their previous qualification and experience upon taking up their functions;

(3)there shall be a system to plan the availability of personnel, in order to ensure the proper completion of all tasks.

(c)The compliance monitoring function referred to in point (a)(4) shall include a feedback system of audit findings to the senior management of the competent authority to ensure implementation of corrective actions as necessary.

(d)The competent authority shall appoint for each field of activity, including the management system, one or more persons with the overall responsibility for the management of the tasks referred to in point (a).

(e)In addition to the requirements in point (a), the management system established and maintained by the competent authority shall comply with Annex I (Part-IS.AR) to Commission Implementing Regulation (EU) 2023/203¹¹ in order to ensure the proper management of information security risks which may have an impact on aviation safety.

[point (e) applicable from 27 March 2031 — Regulation (EU) 2025/23]

ED Decision 2025/006/R

ORGANISATIONAL STRUCTURE

(a)The competent authority should consider all the following elements when deciding on the required organisational structure for GH oversight:

(1)the number of declared GH organisations, including self-handling organisations;

(2)the number of aerodromes where the GH organisations operate;

(3)the possible use of qualified entities and the resources needed to fulfil the continuing oversight obligations;

(4)the size and complexity of the Member State’s aviation industry;

(5)the economic trends indicating growth or decline of GH activities.

(b)The set-up of the organisational structure should ensure that the various tasks and obligations of the competent authority do not rely solely on individuals. The continuing and undisturbed fulfilment of the tasks and obligations of the competent authority should also be guaranteed in the event of illness, accident or leave of individual employees.

(c)The competent authority should take appropriate steps to ensure that the general policy on activities to implement the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts is:

(1)disseminated to and understood by all personnel involved, and

(2)implemented and maintained.

ED Decision 2025/006/R

ORGANISATION AND GENERAL POLICY

(a)It is recommended that the competent authority be organised in such a way that:

(1)there is specific and effective management authority in the conduct of all relevant activities;

(2)the functions and processes described in the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts, AMC and GM can be properly implemented;

(3)the competent authority’s organisational and operating procedures for the implementation of the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts are properly documented and applied;

(4)specific and effective provision is made for communication and coordination, as necessary, with the Agency and the competent authorities of other Member States; and

(5)all functions related to implementing the applicable requirements are adequately described.

(b)The competent authority’s general policy on activities to implement the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts, while satisfying additional national regulatory responsibilities, takes into account in particular:

(1)the provisions of Regulation (EU) 2018/1139,

(2)the provisions of the applicable implementing and delegated acts and their AMC and GM,

(3)the needs of the industry, and

(4)the needs of the Agency and of the competent authority.

(c)The policy defines specific objectives for key elements of the organisation and processes for implementing related activities, including the corresponding control procedures and the measurement of the standard achieved.

ED Decision 2025/006/R

DOCUMENTED POLICIES AND PROCEDURES

(a)The various elements of the organisation involved in the activities related to Regulation (EU) 2018/1139 and its implementing and delegated acts should be documented in order to establish a reference for the establishment and maintenance of this organisation.

(b)The documented policies and procedures should be established in a way that facilitates their use. They should be clearly identifiable, kept up to date and made readily available to all personnel involved in the related activities.

(c)The documented policies and procedures should cover, as a minimum, the following aspects:

(1)policy and objectives,

(2)organisational structure,

(3)responsibilities and associated authority,

(4)procedures and processes,

(5)coordination and communication internally and externally with relevant units or entities,

(6)internal control procedures,

(7)training of personnel,

(8)cross-references to associated documents,

(9)assistance from other competent authorities or the Agency, where required,

(10)ethics, personal conduct and the avoidance of actual or perceived conflicts of interest in the performance of official duties.

(d)If the information is held in more than one document or series of documents, suitable crossreferencing should be conducted, and the referenced documentation should be readily available upon request.

ED Decision 2025/006/R

CONTENT OF PROCEDURES

(a)The Agency should have access, for standardisation purposes, to the competent authority procedures related to the management system and their amendments before conducting an inspection. Those procedures should provide at least the following information.

(1)The competent authority’s organisational structure, with a description of the main processes related to the oversight, including continuing oversight, and functions. This information should demonstrate the allocation of responsibilities within the competent authority and that the competent authority is capable of carrying out the full range of tasks in line with the size and complexity of the Member State’s GH industry. It should also consider the overall proficiency and scope of authorisation of the competent authority’s personnel.

(2)How changes that significantly affect the competent authority’s oversight capabilities are identified and dealt with.

(3)For personnel involved in oversight activities, the minimum requirements for professional qualifications and experience, and principles guiding the appointment (e.g. assessment).

(4)How the following activities are carried out: verification of declarations, performance of continuing oversight, follow-up of findings and observations, enforcement measures and resolution of safety concerns.

(5)Processes in place for disseminating applicable safety information to enable timely responses to a safety problem.

(6)Criteria for planning continuing oversight (the oversight programme), including adequate management of interfaces when conducting continuing oversight (e.g. with aerodrome operations and air operations oversight, or ramp inspections).

(7)Outline of the initial training of newly recruited oversight personnel (taking future activities into account) and of the basic framework for continuing training of oversight personnel.

(b)The procedures in the competent authority’s management system should include any amendments to those procedures.

(c)As part of the continuing monitoring of a competent authority, in addition to the latest amendments of the elements listed in point (a), the Agency may request details of the working methods used, such as instructions or related guidance material used by the personnel conducting oversight.

ED Decision 2025/006/R

INFORMATION SPREAD ACROSS SEVERAL DOCUMENTS

Organisational structure and job descriptions can be found in different documents from the ones containing the detailed working procedures.

ED Decision 2025/006/R

SUFFICIENT PERSONNEL

(a)This GM for the determination of the required personnel refers to the personnel of the competent authority required to fulfil oversight and enforcement responsibilities.

(b)The elements to be considered when determining the necessary personnel and planning their availability can be quantitative or qualitative:

(1)quantitative elements:

(i)the number of organisations providing GH services, which have declared their activity to the competent authority;

(ii)the number of Member States and number of stations where the GH organisation provides services; and

(iii)the number of planned audits and inspections;

(2)qualitative elements:

(i)the size and complexity of the organisations responsible for the provision of GH services, taking into account:

(A)the range of GH services provided by an organisation,

(B)whether a GH organisation provides services locally (at one or more aerodromes in the same Member State) or in more than one Member State,

(C)organisational structure, existence of subsidiaries and number of contracted activities,

(D)whether an organisation is an independent GH service provider, an aircraft operator performing self-handling or providing GH services as an independent GH organisation, or an aerodrome operator providing GH services,

(E)whether a GH organisation or a self-handling aircraft operator is part of a single GH organisation business grouping or a single air carrier business grouping;

(ii)complexity of the GH services provided; for example, the complexity of aircraft exterior cleaning services in comparison with aircraft turnaround coordination or aircraft ground de-icing/anti-icing;

(iii)the safety priorities identified;

(iv)the results of past oversight activities, including audits, inspections and reviews, in terms of risks and regulatory compliance, taking into account:

(A)number and level of findings,

(B)time frame for the implementation of corrective actions, and

(C)maturity of management systems implemented by organisations and their ability to effectively manage safety risks, taking into account information provided by other competent authorities related to activities in the territory of the Member States concerned; and

(v)the size and complexity of the Member State’s aviation industry and the potential increase in activities in the field of civil aviation, which may be an indication of the number of new declarations and changes to existing declarations to be expected.

(c)It is recommended gathering the following data to assess the required number of GH inspectors and their planning:

(1)standard number of audits to be performed to complete the full oversight scope;

(2)standard duration of an audit;

(3)standard working time for audit/inspection preparation, on-site audit, reporting and follow-up, per inspector;

(4)standard number of inspections and unannounced inspections to be performed;

(5)standard duration of inspections, including preparation, reporting and follow-up, per inspector;

(6)minimum number of inspectors and required qualifications for each audit/inspection.

(d)Standard working time could be expressed either in working hours per inspector or in working days per inspector. All planning calculations should then be based on the same unit (hours or working days).

(e)Spreadsheet software may be used to process data defined under points (c) and (d), to assist in determining the total number of working hours/days per oversight planning cycle required for oversight and enforcement activities. Such software could also serve as a basis for implementing a system for planning the availability of personnel.

(f)The following activities can be considered when determining the number of working hours/days per planning period for each qualified inspector:

(1)purely administrative tasks not directly related to oversight,

(2)training,

(3)participation in other projects or tasks, such as oversight in other aviation domains,

(4)planned absence, and

(5)a reserve for unplanned tasks or unforeseeable events.

(g)The elements listed above will enable the competent authority to:

(1)monitor dates when audits and inspections are due and when they have been carried out;

(2)implement a system to plan the availability of personnel; and

(3)identify possible gaps between the number and qualifications of personnel and the required extent of oversight activities.

ED Decision 2025/006/R

FACILITIES AND OFFICE ACCOMMODATION

Facilities and office accommodation include but are not limited to:

(a)adequate offices;

(b)a technical library available to personnel of the competent authority, or another method to ensure receipt, control and distribution of the necessary technical documentation;

(c)office equipment, including computers and other means of communication;

(d)means of transportation; and

(e)personal protective equipment.

ED Decision 2025/006/R

COMPLIANCE MONITORING PROCESS

The formal process for monitoring the compliance of the management system with the relevant requirements and the adequacy of the procedures should be the responsibility of a person or group of persons who:

(a)have functional independence from the units/departments they oversee;

(b)report to the senior management of the competent authority; and

(c)have direct access to the senior management of the competent authority and to appropriate management personnel for safety matters.

ED Decision 2025/006/R

PREREQUISITES FOR GH INSPECTORS

The persons appointed as GH inspectors, who have tasks related to oversight of GH organisations, should meet either of the following criteria:

(a)have operational experience in any GH operations or another aviation domain, appropriate to the assigned tasks, as established by the competent authority; or

(b)have auditing experience in GH or another aviation domain, which is relevant for the oversight of GH activities and organisations performing them, as established by the competent authority; or

(c)if the person has no auditing or GH operational experience, the additional on-the-job training conditions in point (c) of AMC4 ARGH.MGM.200(b) should be complied with.

ED Decision 2025/006/R

TRAINING PROGRAMME

(a)The competent authority should establish a training programme including the assessment of its GH inspectors and a plan for its implementation.

(b)The training programme should cover knowledge, skills and attitudes (KSAs) and should address specific needs of personnel and the competent authority.

(c)For each inspector, the competent authority should:

(1)define the competencies required to perform the oversight tasks;

(2)conduct a training gap analysis before enrolling the inspector in the training programme, to ensure easy recognition of any prior experience, training and qualifications relevant to their function;

(3)establish initial and recurrent training programmes in order to maintain and enhance inspectors’ competency to enable them to achieve the level necessary to perform the allocated tasks; and

(4)ensure that the training meets the established objectives and is reviewed and updated whenever necessary.

(d)The competent authority should have a process for enabling the recognition of an inspector’s previous qualifications and experience in other aviation domains, when relevant to their future tasks and should apply only the necessary additional training to complete the inspector qualifications.

PROVISION OF TRAINING

(e)The training may be provided either by the competent authority’s own qualified trainers or by another suitable training source, which may be a training organisation or adequately qualified individuals.

(f)The trainers should meet the competency and qualification criteria established by the competent authority and described in its documentation. Those criteria should include:

(1)relevant experience in GH operations, as established by the competent authority;

(2)relevant experience or competence in delivery of training (applying training techniques);

(3)communication skills;

(4)safety awareness skills;

(5)behavioural traits indicating professionalism, maturity, judgment, integrity and high personal performance standards.

ED Decision 2025/006/R

INITIAL TRAINING FOR AUTHORITY INSPECTORS

(a)Initial training should cover the KSA components as follows:

(1)The knowledge component should cover the content of this AMC.

(2)The skills component should cover audit/inspection techniques in specific areas of inspection.

(3)The attitude component should be developed throughout the training process, by monitoring the trainee inspectors’ behaviours and attitudes during their assigned tasks and practical exercises and by adjusting the behaviours through discussions and feedback from the instructor throughout the training process.

(b)The competent authority should ensure that the trainee inspectors have successfully completed the first phase of their initial training by passing an assessment with an appropriately qualified assessor.

(c)After having successfully passed the first phase of the initial KSA training, the trainee inspector should undergo on-the-job training. The objectives are as follows:

(1)to familiarise the trainee inspector with the particularities of performing a GH audit/inspection in a real, operational environment, which should be done in accordance with AMC4 ARGH.MGM.200(b); and

(2)to monitor the KSA components in a real-life environment and provide final feedback and guidance.

(d)The competent authority may adapt the duration and depth of the individual training programme of an inspector based on the previous qualifications and experience and competence they achieve.

CONTENT OF THE INITIAL TRAINING FOR AUTHORITY INSPECTORS

(e)The initial training programme for inspectors should include the following content, to cover the KSA components, adjusted to their role, current knowledge, experience and skills.

(f)The training programme should be updated, as needed, to reflect the latest changes in aviation legislation and the aviation industry.

(g)AVIATION LEGISLATION

(1)the Chicago Convention and the relevant International Civil Aviation Organization (ICAO Annexes and Documents;

(2)the relevant requirements of Regulation (EU) 2018/1139, including the enforcement measures specified in Article 62 points (1)(e) and (9);

(3)Commission Implementing Regulation(EU) 2025/23, Commission Delegated Regulation (EU) 2025/20, the relevant parts of Regulations (EU) No 965/2012, (EU) No 139/2014, (EU) 2022/1645, and other applicable aviation regulations, as well as the AMC and GM associated with those regulations;

(4)Regulation (EU) No 376/2014 on occurrence reporting and analysis and follow-up of occurrences in civil aviation and the related Commission Implementing Regulation (EU) 2015/1018;

(5)any other relevant international or national aviation legislation.

(h)AUDITING TECHNIQUES

(1)theory of audits and inspections, auditing and reporting techniques, as well as quality and safety assurance, including aspects of performing remote inspections;

(2)competent authority procedures relevant to inspectors’ tasks;

(3)acceptability and auditing of management systems and the safety management system (SMS);

(4)methodology to assess AltMoC;

(5)rights and obligations of inspecting personnel of the competent authority.

(i)TECHNICAL TRAINING PER GH ACTIVITY

(1)technical training on specific GH activities as listed in Article 2 of Commission Delegated Regulation (EU) 2025/20, appropriate to the role and tasks of the inspector;

(2)dangerous goods;

(3)operation of ground support equipment (GSE), as applicable;

(4)security;

(5)other suitable technical training appropriate to the role and tasks of inspectors, including familiarisation with the applicable industry standards.

(j)SMS TRAINING AND OTHER AREAS OF PARTICULAR INTEREST

These include, but are not limited to:

(1)management systems;

(2)assessment of the effectiveness of the SMS, in particular hazard identification and safety risk assessment, safety assurance principles and root cause analysis;

(3)accident and incident investigation training, with a focus on root cause analysis;

(4)non-punitive reporting techniques in the context of the implementation of a ‘just culture’;

(5)management of change;

(6)human factors principles.

(k)AERODROME TRAINING FOR UNESCORTED ACCESS TO THE MOVEMENT AREA

Unescorted access to the movement area and other operational areas of the aerodrome that are relevant to the oversight of GH activities, in accordance with the training for authority inspectors included in Regulation (EU) No 139/2014.

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ON-THE-JOB TRAINING FOR INSPECTOR QUALIFICATION

(a)The competent authority should ensure that on-the-job training is undertaken by trainee inspectors as part of their initial training, after they have successfully completed the first phase of their initial KSA training. On-the-job training should be conducted by a competent person.

(b)The content and duration of the on-the-job training should be adapted to the particular training needs of every trainee inspector and should take into account the following aspects:

(1)the scope and complexity of the inspector’s tasks,

(2)the application of the KSA concepts developed in the first phase of the initial training,

(3)any prior experience as an inspector.

(c)The on-the-job training should focus on the oversight tasks that the inspector will perform. It should include a number of GH audits/inspections, which the competent authority may decide on a case-by-case basis, based on an evaluation of the trainee’s performance. If the trainee inspector has no auditing or GH operational experience before starting the initial training, they should perform GH inspector tasks, including audits and inspections, under supervision for a longer period — as determined by the competent authority — before being allowed to work as a qualified GH inspector.

(d)The scope and elements to be covered during the on-the-job training are as follows:

(1)preparation for an audit/inspection:

(i)sources of information for the preparation for an audit/inspection,

(ii)areas of concern and/or open findings,

(iii)selection of GH organisation to be audited/inspected, and

(iv)task allocation among the members of the audit/inspection team;

(2)administrative issues of the inspection:

(i)GH inspector credentials, rights and obligations,

(ii)aerodrome access procedures,

(iii)airside safety and security procedures, and

(iv)briefing on the GH inspector toolkit (fluorescent vest, anti-electrostatic clothing, checklists, digital camera, torch, safety shoes, hearing protection, etc. depending on the case);

(3)audit/inspection:

(i)introduction (opening meeting),

(ii)on-site activities (audit/inspection according to the area of expertise of the trainee),

(iii)findings (identification, categorisation, evidencing, reporting), and

(iv)corrective actions (enforcement);

(4)closing meeting (debrief on the conclusions of the audit/inspection);

(5)preparation, completion and delivery of the audit/inspection report;

(6)human factors elements:

(i)cultural aspects,

(ii)resolution of disagreements and conflicts, and

(iii)auditee stress;

(7)team leading, if required;

(8)post-audit/-inspection procedures, such as monitoring the status of open audit findings, follow-up audits/inspections and closing the findings after appropriate action has been taken by the GH organisation.

(e)The trainee GH inspector should be assessed by the GH inspector who provides the training. A trainee GH inspector should be considered to have successfully completed their on-the-job training only after demonstrating to the GH inspector who provides the training that they possess the professional competence, knowledge, judgement and ability to perform GH inspections and audits in a real, operational environment, in accordance with the applicable requirements.

(f)The competent authority should ensure that the trainee GH inspector has achieved the required competence before they are authorised to perform their role without supervision.

ED Decision 2025/006/R

QUALIFICATION OF INSPECTORS AFTER SUCCESSFUL COMPLETION OF INITIAL TRAINING

(a)Upon successful completion of the initial training, including on-the-job training, the competent authority should issue a formal qualification statement for each qualified GH inspector, listing their privileges.

(b)The competent authority should put in place a system that ensures that their inspectors meet at all times the qualification criteria for eligibility, training and recent experience.

ED Decision 2025/006/R

CONTINUED COMPETENCE OF INSPECTORS

(a)Once an inspector is qualified, the competent authority should ensure that they maintain their qualification and remain competent to perform the allocated tasks. This should be done by developing and implementing a process for recurrent training and assessment. The recurrent training and assessment should take place at regular intervals, of no longer than 36 months.

(b)The recurrent training programme should address, as appropriate to the role of the inspector, at least the following aspects:

(1)changes in legislation, the operational environment and technologies in the field of aviation;

(2)competent authority procedures relevant to the inspector’s tasks;

(3)technical training, including training on GH-specific subjects, appropriate to the role and tasks of the inspector; and

(4)results from past oversight.

(c)Training courses with a fixed interval for recurrence established through another regulation (e.g. dangerous goods training) should be maintained as such.

(d)The training to ensure continued competence of inspectors may include, whenever possible, an exchange scheme for inspectors from different Member States, to enable the efficient implementation of cooperative oversight and the standardisation of the oversight process while improving or maintaining inspectors’ competence.

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RECENT EXPERIENCE TO MAINTAIN QUALIFICATION OF GH INSPECTORS

(a)A GH inspector is considered to remain qualified if they have performed a minimum of two
on-site GH audits/inspections or if they have assisted other competent authorities in performing a minimum of two GH audits/inspections in the previous 12 months.

(b)If a GH inspector loses their qualification as a result of not meeting any of the conditions mentioned in point (a), they may be requalified by completing the minimum number of audits/inspections under the supervision of a qualified inspector. The missed audits/inspections should take place within three months of the deadline for fulfilling the conditions in point (a).

(c)If a GH inspector loses their qualification because they have not performed any audits/inspections for a period between 12 and 24 months, they may be requalified by the competent authority only after successfully completing on-the-job training and any recurrent training required.

(d)If more than 24 months passed since a GH inspector’s last audit/inspection, they may be requalified by the competent authority only after successfully completing initial training, including on-the-job training.

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PRACTICAL TRAINING VERSUS ON-THE-JOB TRAINING

Practical training, as part of the initial training that inspectors receive, refers to various methods used during training to encourage the trainee to apply their knowledge and skills and help them develop the appropriate attitudes. It involves exercises that simulate the real-life working environment.

On-the-job training requires the participation of the trainee inspector in real audits/inspections, either as an observer or as a GH inspector under supervision.

ED Decision 2025/006/R

DOCUMENTS RELEVANT TO THE TRAINING FOR GH INSPECTORS

The following non-exhaustive list of ICAO Annexes and Documents, as well as industry standards and industry best practices, appropriate to the role of the GH inspector, are relevant to the training programme referred to in AMC3 ARGH.MGM.200(b):

(a)ICAO documentation:

(1)Annex 6 — Operation of Aircraft – relevant standards and recommended practices for GH,

(2)Annex 9 — Facilitation,

(3)Annex 14 — Aerodromes – relevant standards and recommended practices for GH,

(4)Annex 18 — The Safe Transport of Dangerous Goods by Air,

(5)Annex 19 — Safety Management,

(6)Doc 10121 — Manual on Ground Handling,

(7)Doc 9284 — Technical Instructions for the Safe Transport of Dangerous Goods,

(8)Doc 9640 — Manual of Aircraft Ground De-icing/Anti-icing Operations,

(9)Doc 9977 — Manual on Civil Aviation Jet Fuel Supply,

(10)Doc 10070 — Manual on the Competencies of Civil Aviation Safety Inspectors,

(11)Doc 10102 — Guidance for Safe Operations Involving Aeroplane Cargo Compartments,

(12)Doc 10147 — Guidance on a Competency-based Approach to Dangerous Goods Training and Assessment,

(13)Doc 10151 — Manual on Human Performance (HP) for Regulators;

(b)industry standards and best practices, as applicable:

(1)Joint Inspection Group (JIG) standards related to fuelling operations,

(2)Society of Automotive Engineers (SAE) standards related to de-icing and anti-icing operations,

(3)IATA Ground Operations Manual (IGOM), IATA Airport Handling Manual (AHM), and IATA Cargo Handling Manual (ICHM), Live Animals Regulations (LAR),

(4)EN standards for GSE (EN 12312-1 to 12312-20 and EN 1915-1 to 1915-4),

(5)International Business Aviation Council (IBAC) International Standard for Business Aircraft Handlers regarding GH for business aviation operations (IS-BAH).

ED Decision 2025/006/R

QUALIFICATION OF INSPECTORS

(a)The term ‘qualification’ denotes adequacy for a purpose. Inspectors may become qualified by fulfilling the necessary conditions, such as completing the required training, holding a diploma or degree, or gaining suitable experience. Qualification also includes the ability, capacity, knowledge and skills that are required to perform a task or that make a person eligible for a duty, an office, a position, a privilege or a status.

(b)Certain posts may, by nature, be associated with the possession of certain qualifications in a specific field (e.g. civil or mechanical engineering, safety management, chemistry, environmental science, etc.). In such cases, the person occupying the post is expected to possess the necessary qualifications at a level that is in accordance with the applicable national or EU legislation.

ED Decision 2025/006/R

RECURRENT ASSESSMENT OF AN INSPECTOR’S COMPETENCE

A recurrent assessment is the equivalent of a proficiency check.

It is recommended that the competent authority include recurrent assessment in the training process to ensure the maintenance of an inspector’s competence.

(a)The recurrent assessment consists of knowledge and skills checks during a real-time inspection or audit.

(b)The inspector’s performance is evaluated against the objectives (usually the tasks included in their job description) established for their role.

(c)Failure to achieve the expected outcome is addressed in a training session, to maintain the competence of the inspector at the expected level.

(dIt is recommended that recurrent assessments be conducted at intervals shorter than
36 months and that evidence of such assessments be kept in the form of checklists containing the objectives referred to in point (b).

Regulation (EU) 2025/23

(a)The competent authority may allocate to qualified entities tasks related to the registration of declarations or continuing oversight of ground handling organisations subject to Regulation
(EU) 2018/1139 and its delegated and implementing acts.

(b)When allocating tasks to a qualified entity, the competent authority shall ensure that:

(1)that authority has a system in place to initially and continually assess whether the qualified entity complies with Annex VI to Regulation (EU) 2018/1139;

(2)the system referred to in point (1) and the results of the assessments are documented;

(3)the authority has established a documented agreement with the qualified entity, approved by both parties at the appropriate management level, which clearly defines:

(i)the tasks to be performed;

(ii)the declarations, reports and records to be provided;

(iii)the technical conditions to be met in performing such tasks;

(iv)the related liability coverage;

(v)the protection given to information acquired in carrying out such tasks.

(c)The competent authority shall establish procedures to ensure that all the information related to the submission of a declaration by a ground handling organisation is promptly communicated between the competent authority and the qualified entity.

(d)The competent authority shall ensure that the internal audit process and safety risk management process referred to in point ARGH.MGM.200(a)(4) of this Annex cover all tasks related to the acceptance of declarations or continuing oversight tasks performed on its behalf.

(e)For the oversight of the ground handling organisation’s compliance with point ORGH.MGM.201 of Annex I to Delegated Regulation (EU) 2025/20, the competent authority may allocate tasks to qualified entities in accordance with point (a) or to any relevant authority responsible for information security or cybersecurity within the Member State. When allocating tasks, the competent authority shall ensure that:

(1)all aspects related to aviation safety are coordinated and taken into account by the qualified entity or the relevant authority;

(2)the results of the oversight activities performed by the qualified entity or the relevant authority are integrated in the overall oversight files of the ground handling organisation;

(3)its own information security management system, established in accordance with point ARGH.MGM.200(e), covers all the continuing oversight tasks performed on its behalf.

[point (e) applicable as of 27 March 2031 — Regulation (EU) 2025/23]

Regulation (EU) 2025/23

(a)The competent authority shall have a system in place to identify changes that affect its capability to perform its tasks and discharge its responsibilities as laid down in Regulation
(EU) 2018/1139 and its delegated and implementing acts. That system shall enable it to take action, as appropriate, to ensure that its management system remains adequate and effective.

(b)The competent authority shall update its management system to reflect any changes to Regulation (EU) 2018/1139 and its delegated and implementing acts in a timely manner.

(c)The competent authority shall notify the Agency of changes affecting its capability to perform its tasks and discharge its responsibilities as laid down in Regulation (EU) 2018/1139 and its delegated and implementing acts.

Regulation (EU) 2025/23

(a)For changes managed and notified to the competent authority in accordance with the procedure set out in point IS.D.OR.255(a) of the Annex to Delegated Regulation (EU) 2022/1645, the competent authority shall include the review of such changes in its continuing oversight in accordance with the principles laid down in point ARGH.OVS.300 of this Annex. If any
non-compliance is found, the competent authority shall notify the organisation thereof, request further changes and act in accordance with point ARGH.OVS.325 of this Annex.

(b)For other changes referred to in point IS.D.OR.255(b) of the Annex to Delegated Regulation
(EU) 2022/1645, the competent authority shall check the ground handling organisation’s compliance with the applicable requirements as part of the oversight tasks.

[point ARGH.MGM.211 applicable from 27 March 2031 — Regulation (EU) 2025/23]

Regulation (EU) 2025/23

(a)The competent authority shall establish a system of record-keeping that ensures adequate storage, accessibility and reliable traceability of:

(1)the management system’s documented policies and procedures;

(2)training, qualification and authorisation of the competent authority’s personnel;

(3)if applicable, the allocation of tasks to qualified entities, covering the elements required by point ARGH.MGM.205 as well as the details of tasks allocated;

(4)declaration process and continuing oversight of organisations responsible for the provision of ground handling services;

(5)the evaluation and notification to the Agency of AltMoC proposed by organisations responsible for the provision of ground handling services and the assessment of AltMoC used by the competent authority itself;

(6)findings, corrective actions and date of action closure, and observations;

(7)enforcement measures taken;

(8)safety information and follow-up measures;

(9)the use of flexibility provisions laid down in Article 71 of Regulation (EU) 2018/1139.

(b)The competent authority shall maintain an up-to-date list of all the declarations it has received.

(c)The records referred to in points (a) and (b) shall be kept for a minimum period of 5 years, subject to applicable Union data protection law.

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GENERAL

(a)The record-keeping system should ensure that all records are accessible whenever needed within a reasonable time. These records should be organised in a way that ensures traceability and retrievability throughout the required retention period.

(b)Records should be kept in paper form or in electronic format, or in a combination of both. Records stored on microfilm or an optical disc are also acceptable. The records should remain legible and accessible throughout the required retention period. The retention period runs from when the record was created or when it was most recently amended.

(c)Paper systems should use robust material, which can withstand normal handling and filing. Computer systems should have at least one backup system, which should be updated within 24 hours of any new entry. Computer systems should include safeguards against the unauthorised alteration of data.

(d)All computer hardware used to store backup data should be kept in a different location from that containing the working data and in an environment that ensures that the data remains in good condition. When hardware or software changes take place, special care should be taken to ensure that all necessary data continues to be accessible, at least throughout the period specified in point ARGH.MGM.215.

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RECORDS RELATED TO THE COMPETENT AUTHORITY’S MANAGEMENT SYSTEM

Records related to the competent authority’s management system should include, as a minimum and as applicable:

(a)the documented policies and procedures;

(b)the personal files of personnel of the competent authority, with supporting documents related to training and qualifications;

(c)the results of the competent authority’s internal compliance monitoring and safety risk management processes, including audit findings and corrective actions; and

(d)if applicable, the contract(s) established with qualified entities performing oversight tasks on behalf of the competent authority.

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RECORDS RELATED TO GH ORGANISATIONS

Records related to a GH organisation should include:

(a)declarations received or changes thereto;

(b)a copy of the continuing oversight programme listing the dates when audits are due and when such audits have been carried out;

(c)continuing oversight records, including records from all audits and inspections;

(d)copies of all relevant correspondence;

(e)details of any exemptions.

SUBPART OVS — OVERSIGHT AND ENFORCEMENT

Regulation (EU) 2025/23

(a)The competent authority shall verify both of the following during the oversight process:

(1)the continued compliance of the ground handling organisation with Delegated Regulation (EU) 2025/20 and the terms of its declaration;

(2)the implementation of appropriate safety measures mandated by the competent authority in accordance with point ARGH.GEN.135.

(b)The oversight referred to in point (a) shall:

(1)be supported by documentation intended to provide guidance for the competent authority personnel to perform their functions;

(2)provide the ground handling organisation concerned with the results of the oversight;

(3)be based on audits and inspections, including ramp and unannounced inspections, when appropriate;

(4)provide the competent authority with the evidence needed if further action is required, including the measures referred to in point ARGH.OVS.325(d).

(c)The scope of the oversight shall consider the results of past oversight activities of the competent authority and the safety priorities as identified through the European Plan for Aviation Safety.

(d)The competent authority shall collect and process any information deemed useful for oversight and risk-based oversight, including for unannounced inspections, as appropriate.

(e)Where more than one competent authority is responsible for the oversight of the same organisation, the oversight shall be conducted in accordance with point ARGH.OVS.330.

(f)For the oversight of the organisation’s compliance with point ORGH.MGM.201 of Annex I to Delegated Regulation (EU) 2025/20, in addition to complying with points (a) to (d) of this point, the competent authority shall review any exemption granted under point IS.D.OR.200(e) of the Annex to Delegated Regulation (EU) 2022/1645 following the applicable oversight audit cycle and whenever changes are implemented in the scope of work of the organisation.

[point (f) applicable from 27 March 2031 — Regulation (EU) 2025/23]

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GENERAL

(a)The responsibility for the safe conduct of GH services lies with the GH organisation. A declaration policy recognises that the GH organisation is the primary holder of responsibility for monitoring the safety of its operation. The objective of ensuring safety of operations cannot be attained unless the organisation is prepared to accept the implications of this policy, including those of committing the necessary resources to its implementation. The content of Part-ORGH (Annex I to Commission Delegated Regulation (EU) 2025/20) is crucial to the success of the policy, as it requires that the GH organisation establish a management system.

(b)The competent authority assesses the organisation’s compliance with the applicable requirements, including the suitability and effectiveness of the organisation’s management system, on a continuing basis.

(c)The accountable manager of a GH organisation is accountable to the competent authority and to those who appoint him or her. Therefore, the competent authority cannot accept a situation in which the accountable manager is denied sufficient funds, human resources or influence to rectify deficiencies identified in the management system.

(d)Oversight of the organisation includes the review and assessment of the qualifications of the nominated persons.

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EVALUATION OF A GH ORGANISATION’S SAFETY RISK MANAGEMENT

(a)As part of the oversight scope, the competent authority should evaluate the GH organisation’s safety risk management process and its capability to identify hazards, assess risks and apply effective mitigation measures. The process and capabilities should be identifiable within the GH organisation’s management system.

(b)As part of the continuing oversight of a GH organisation, the competent authority should also remain satisfied with the effectiveness of the organisation’s safety risk management process.

(c)The competent authority should establish a methodology for evaluating the GH organisation’s safety risk management process. The evaluation should be considered positive if the GH organisation demonstrates its competence and capability to:

(1)understand the hazards and their consequences for its activities;

(2)assess the safety risks related to the hazards identified;

(3)be clear on where those hazards may exceed acceptable safety risk limits;

(4)identify and implement mitigation measures to minimise or remove the safety risks, which could be reflected, for example, in the following:

(i)applying effective operational procedures for the provision of the GH services subject to the hazards identified;

(ii)assessing the competence and continued competence of its personnel to perform their duties and implementing any necessary training, conducting adequate recurrent assessment and retraining of GH personnel and ensuring the availability of sufficient personnel for GH duties;

(iii)equipping the GSE with proximity sensors or applying equivalent controls through procedures to prevent aircraft damage.

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METHODOLOGY

The methodology established by the competent authority for evaluating the safety risk management of an organisation is a set of processes, procedures, guidelines and tools applied consistently by a competent authority to discharge its oversight responsibilities in the aviation domains within the scope of Regulation (EU) 2018/1139. It should be understood that regardless of the methodology applied by one competent authority, the outcome of the evaluation process is expected to be the same for all competent authorities and measured against the applicable requirements.

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INDUSTRY AUDITS

(a)As part of data and information collected to support the competent authority’s oversight and to develop the basis for risk-based oversight, the authority may take into account the results of industry audits on the GH organisation conducted by third-party auditors.

(b)The competent authority may credit such industry audits if they meet the following criteria:

(1)the scope of the industry audits can easily be mapped against Annex I (Part-ORGH) and Annex II (Part-GH.OPS) to Commission Delegated Regulation (EU) 2025/20, as applicable;

(2)the audit content is fit for purpose, is objective, the audit process is systematic and the auditors have no conflict of interest with the audited organisation and are properly trained;

(3)audit results are accessible to the competent authority, and the relevant safety information from those results can be shared with the competent authorities responsible for the oversight of the GH organisation, in accordance with Article 62(9) of Regulation (EU) 2018/1139;

(4)the competent authority has access to the third-party industry auditor to determine continued compliance with the applicable requirements.

(c)It should be understood that the third-party industry audits do not replace the oversight activities of the competent authority. The competent authority remains responsible for oversight at all times.

(d)Conformity of a GH organisation with industry standards or good practices proven through a third-party industry audit does not result in automatic recognition of compliance with Commission Delegated Regulation (EU) 2025/20.

ED Decision 2025/006/R

INDUSTRY AUDITS IN THE SCOPE OF OVERSIGHT

Various organisations may perform an audit on a GH organisation to verify how it implements different procedures as part of its contractual obligations. The competent authority could decide to use, as relevant, the results from those audits for the purpose of oversight or to better define a GH organisation’s safety profile as a basis for risk-based oversight, alongside safety occurrence reports.

Below is a non-exhaustive list of possible industry auditing organisations:

(a)an aerodrome operator, to verify that the GH organisation implements the aerodrome procedures or programmes applicable to it under Regulation (EU) No 139/2014, such as, for example, the foreign object debris (FOD) programme, operation in adverse weather conditions, pedestrian access or driving in airside areas;

(b)an aircraft operator, to verify that the GH organisation implements the aircraft operator’s procedures applicable to it as per Regulation (EU) No 965/2012 and Annex VII to Regulation (EU) 2018/1139;

(c)a third-party industry auditing organisation performing the audit on behalf of an aircraft operator or an aerodrome operator.

Regulation (EU) 2025/23

(a)The competent authority shall establish and maintain an oversight programme covering the oversight activities required by ARGH.OVS.300.

(b)The oversight programme shall be developed and implemented taking into account the following elements:

(1)the services provided by the ground handling organisation;

(2)the complexity of the ground handling organisation;

(3)the results of past oversight, where applicable;

(4)the assessment of risks associated with the ground handling services provided by the ground handling organisation and its risk exposure;

(5)the ground handling organisation’s safety performance, where applicable.

(c)The competent authority shall apply an oversight planning cycle not exceeding 48 months, starting from the date when the initial declaration is received. The oversight programme and planning shall reflect the safety performance of the ground handling organisation, as well as its risk exposure. The oversight cycle shall include audits and inspections, including unannounced inspections, as appropriate.

(d)The oversight planning cycle may be extended to maximum 72 months if the competent authority has established that, during the previous audit cycle:

(1)the ground handling organisation has demonstrated an effective management system, including compliance monitoring, identification of aviation safety hazards and management of associated risks;

(2)the ground handling organisation has continually demonstrated that it has full control over all changes in accordance with point ORGH.GEN.130 of Annex I to Delegated Regulation (EU) 2025/20;

(3)no level 1 findings have been issued;

(4)all corrective actions have been implemented within the time period accepted or extended by the competent authority in accordance with point ARGH.OVS.325(d) of this Annex.

(e)The oversight cycle may be reduced if there is evidence that the safety performance of the ground handling organisation has decreased or where specific hazards in the local conditions at the aerodrome of operation require enhanced oversight.

(f)The oversight programme shall include records of the dates when audits and inspections are due and when they have been carried out.

ED Decision 2025/006/R

PROCEDURES FOR OVERSIGHT OF GH ORGANISATIONS

(a)The competent authority should appoint an inspector for each GH organisation with overall responsibility for supervising, and liaising with, the organisation’s management and for reporting on compliance with the requirements applicable to its operation. When more than one inspector is assigned to a GH organisation, their responsibilities should be clearly defined.

(b)Inspections, audits and oversight procedures, of a scale and frequency commensurate with the organisation’s operations, should include, but not be limited to:

(1)the organisation’s management system;

(2)safety management, safety risk identification and mitigation actions;

(3)reporting records;

(4)manuals and procedures;

(5)training programmes and records and written examples of training management;

(6)performance of GH activities during the aircraft turnaround process;

(7)GSE, including records of its maintenance;

(8)operational procedures, training and documentation regarding dangerous goods.

(c)The following types of inspections should be included, as part of the oversight programme:

(1)inspection of documents and records;

(2)inspection of passenger acceptance in view of the correct application of procedures related to the safe transportation of dangerous goods in baggage and on the person;

(3)inspection of GH activities during turnaround, including passenger boarding and disembarkation;

(4)inspection of training of GH personnel;

(5)inspection of cargo operations (where applicable), including the handling of dangerous goods.

(d)An inspection/audit should focus on the items selected for the scope of that inspection/audit. Inspections and audits may be conducted jointly or separately. They may also be coordinated with those conducted by the competent authorities responsible for other aviation areas.

(1)Joint audits with competent authorities for other aviation areas may be performed to increase the effectiveness of examining the interfaces between different players at the aerodrome level, such as aerodrome operators, GH organisations and aircraft operators.

(2)Competent authority inspectors from other domains may also be involved in audits or inspections of GH activities in which they are competent, such as flight operations inspectors, aerodrome inspectors, or ramp inspectors competent in the oversight of dangerous goods, aircraft unloading/loading, de-icing/anti-icing operations, refuelling operations, aircraft pushback and towing operations, or GSE maintenance.

(e)Inspections may, at the discretion of the competent authority, be conducted with or without prior notification of the GH organisation.

(f)In accordance with the provisions of Article 89 of Regulation (EU) 2018/1139, inspectors should take account of any indication of significant deterioration in the organisation’s financial situation that may have an impact on safety. However, this should not imply that the assessment of the organisation’s economic or financial situation is a responsibility of the competent authority. If significant deterioration is detected, the competent authority should immediately inform the competent authority designated for the implementation of the Council Directive on Groundhandling (Council Directive 96/67/EC). The competent authority should also increase its technical surveillance of the provision of GH services, with a particular emphasis on upholding safety performance and the effectiveness of the organisation’s management system.

(g)The nature or magnitude of non-compliance identified by the competent authority will serve to support its continuing confidence in the organisation, or, alternatively, may erode that confidence. In the latter case, the competent authority will need to review any identifiable shortcomings of the management system and take appropriate action if required.

ED Decision 2025/006/R

AUDITING

(a)The oversight programme should indicate which aspects will be covered by each audit.

(b)Part of an audit should concentrate on the organisation’s compliance monitoring reports, produced by designated personnel, to determine whether the organisation identifies and corrects its problems.

(c)On concluding the audit, the auditing inspector should complete an audit report, including all findings.

ED Decision 2025/006/R

REGULAR REVIEW OF THE OVERSIGHT PROGRAMME

(a)To ensure that its oversight programme is adequately maintained, as required by point ARGH.OVS.305, the competent authority should regularly review the oversight planning cycle and related oversight programme for each organisation to ensure that they remain adequate following any changes in the complexity or safety performance of the organisation.

(b)When reviewing the oversight planning cycle and related oversight programme, the competent authority should also consider any relevant information collected in accordance with point ORGH.GEN.160 of Delegated Regulation (EU) 2025/20 and points ARGH.OVS.300(c) and (d).

ED Decision 2025/006/R

OVERSIGHT PROGRAMME AND PLANNING

(a)When defining the oversight programme and planning cycle for a GH organisation, the competent authority should assess the risks related to the activity of each organisation and adapt the oversight to the level of risk identified and to the organisation’s ability to effectively manage those risks. The following elements should be considered to assess the exposure of a GH organisation to risk and its safety performance:

(1)information from the GH organisation’s annual monitoring of safety performance, as referred to in AMC1 ORGH.MGM.200(b)(2)(iii);

(2)information from the safety reports related to the organisation’s GH activities;

(3)types of GH services provided at each aerodrome and the specific operational context at the aerodromes;

(4)specific procedures implemented by the organisation stemming from flexibility provisions in Article 71 of Regulation (EU) 2018/1139 or AltMoC;

(5)number of contracted services in the scope of GH service provision;

(6)the effectiveness of the organisation’s management system in addressing
non-compliance;

(7)any other safety-relevant data resulting from audits and inspections, including industry audits;

(8)the implementation by the GH organisation of industry standards and good practices, based on the results of the evaluation referred to in point ARGH.OVS.310.

(b)The oversight programme should follow a risk-based approach, considering the data collected under point (a), and should be developed on a yearly basis.

(c)The competent authority should include all GH organisations in the programme no later than 12 months after the date it receives the first declaration.

(d)When deciding on the number of stations included in the oversight programme to complete the scope of oversight, the competent authority should consider the elements of point ARGH.OVS.305(b) applicable to the station, as well as the result of the oversight of the GH organisation’s management system.

(e)Additional audits and inspections of specific GH organisations may be included in the oversight programme based on assessments of associated risks carried out within occurrence reporting schemes.

(f)The sections of the oversight programme dealing with inspections of GH activities performed during turnaround should be developed based on geographical location, considering aerodrome activity and focusing on key issues that can be inspected in the time available without unnecessarily delaying operations.

(g)The competent authority should include, as part of its oversight, meetings between the accountable manager and the competent authority to ensure that both remain informed of significant issues, at a frequency agreed between the competent authority and the GH organisation.

ED Decision 2025/006/R

STATION OVERSIGHT

(a)A low safety performance demonstrated at the level of the management system of a GH organisation may trigger more frequent inspections at individual stations by the national competent authorities of the aerodromes where that GH organisation provides services.

(b)Likewise, a high safety performance demonstrated at the level of the management system of a GH organisation may provide sufficient evidence to enable the national competent authorities responsible for station oversight to reduce the frequency of audits and inspections at the stations in their state.

ED Decision 2025/006/R

OVERSIGHT PLANNING CYCLE

(a)The competent authority should schedule audits and inspections appropriate to each GH organisation. The planning of audits and inspections should consider the effectiveness of the organisation’s capability to identify hazards and manage the safety risks within its organisation and operation. Inspectors should work in accordance with the schedule provided to the GH organisation.

(b)When the competent authority varies the frequency of audits or inspections as a result of its assessment of the GH organisation’s safety performance, it should ensure that all aspects of the GH organisation’s operation are audited and inspected within the applicable oversight planning cycle.

(c)If the competent authority wishes to align the oversight planning cycle with the calendar year, it should shorten the first oversight planning cycle accordingly.

(d)The oversight planning cycle and the related oversight programme should be reviewed annually.

(e)Audits should include at least one on-site audit of the GH organisation within each oversight planning cycle.

ED Decision 2025/006/R

STATION OVERSIGHT OF ORGANISATIONS PROVIDING GH SERVICES IN MORE THAN ONE MEMBER STATE

(a)When planning station oversight to complete the oversight programme for the purpose of conducting cooperative oversight of an organisation providing GH services in more than one Member State, the competent authorities involved should agree on a minimum overall number of stations to be overseen within an oversight cycle.

(b)The agreed overall number of stations should be relevant to the safety performance of the GH organisation.

(c)The following criteria should be considered as a minimum for the selection of stations to be audited or inspected:

(1)an even spread of stations across the Member States where the GH organisation provides services;

(2)the volume of activity at each of those stations; and

(3)the main risk areas identified.

(d)The GH organisation subject to the oversight should be informed about the planning of that oversight.

ED Decision 2025/006/R

ENHANCED OVERSIGHT DUE TO LOCAL CONDITIONS AT THE AERODROME OF OPERATION

Specific hazards posed by the local conditions at the aerodrome of operation that may require enhanced oversight include but are not limited to:

(a)operations requiring de-icing/anti-icing during cold seasons;

(b)congested traffic in the movement area that leads to frequent GH events;

(c)aerodromes working on a seasonal basis (usually during summer), resulting in disruptions of scheduled operations and the use of temporary workers during the peak season.

Regulation (EU) 2025/23

For the purpose of gathering, exchanging and disseminating relevant information between the Commission, the Agency and the national competent authorities, the Agency, involving expertise provided by Member States, shall evaluate, against objective criteria, the content of industry standards and their updates, when used by ground handling organisations on a voluntary basis to discharge their responsibilities regarding the safe provision of ground handling services.

ED Decision 2025/006/R

EVALUATION OF A RECOGNISED INDUSTRY STANDARD

(a)A recognised industry standard is a standard that has been approved by a standardisation body such as the European Committee for Standardization (CEN), European Committee for Electrotechnical Standardization (CENELEC), or the International Organization for Standardization (ISO), or mandated by legal requirements.

(b)The process of evaluating recognised industry standards that have been certified by an appropriately accredited organisation may be reduced to confirming that they address the scope of Annex I or Annex II to Commission Delegated Regulation (EU) 2025/20, as applicable.

ED Decision 2025/006/R

OBJECTIVE CRITERIA FOR INDUSTRY STANDARDS

(a)Industry standards subject to the evaluation referred to in point ARGH.OVS.310 should meet the following criteria as a minimum:

(1)they are developed, maintained and endorsed with the participation of experts from relevant industry stakeholders;

(2)they address the scope of Annex I and/or II to Commission Delegated Regulation (EU) 2025/20, as applicable, with sufficient details to enable implementation of the related implementing rules;

(3)they are based on experience in the field and have proven themselves through testing;

(4)they are supported by scientific and/or technical data and documentation, safety tests and safety impact assessments, as applicable;

(5)they include technical, operational and, if applicable, human factors specifications for their safe implementation;

(6)they clearly identify the responsibilities of the persons involved in their application;

(7)they contain procedures for continuing review and improvement, to include lessons learned from daily operations and consider relevant innovations in the field.

RELEVANT INDUSTRY STAKEHOLDERS

(b)The industry stakeholders represented in the development, maintenance and endorsement of an industry standard should include but not be limited to aircraft operators, GH organisations, aerodrome operators, product manufacturers, GSE manufacturers, aircraft manufacturers, and regional and global industry associations thereof, as applicable. The aim of their inclusion is to ensure that all stakeholders involved in the development and maintenance of industry standards are also involved in their endorsement.

ED Decision 2025/006/R

OVERSIGHT OF ORGANISATIONS THAT USE INDUSTRY STANDARDS AND GOOD PRACTICES

(a)For the oversight of a GH organisation that applies industry standards and good practices, the competent authority should verify that the actual implementation of the standards and good practices in the GH organisation’s daily operation complies with Commission Delegated Regulation (EU) 2025/20.

(b)When a GH organisation declares that it applies industry standards and good practices to comply with Commission Delegated Regulation (EU) 2025/20, the competent authority should use this as complementary information to support its risk-based oversight. The implementation of industry standards and good practices by an organisation should not be assessed in isolation from the other elements to be considered by the competent authority for its oversight.

(c)The competent authority may decide to what extent it intends to use the results of auditing programmes that verify a GH organisation’s conformity with the industry standards and good practices.

ED Decision 2025/006/R

EXPERIENCE IN THE FIELD, SCIENTIFIC DOCUMENTATION AND SAFETY TESTS SUPPORTING THE DEVELOPMENT OF INDUSTRY STANDARDS AND GOOD PRACTICES

(a)It is expected that industry standards related to products such as the following are supported by scientific documentation and safety-relevant tests:

(1)GSE,

(2)de-icing/anti-icing fluids,

(3)fuel.

(b)It is expected that good practices in the aviation industry covering GH processes and operations, the use of products and organisational aspects are based on years of experience in the field, with trial and error proving that certain practices are better than others. It can be difficult to prove that good practices are based on scientific evidence or safety tests. Indeed, they are sometimes the result of a safety impact assessment and may be subject to a series of safety tests before being disseminated or used on a larger scale.

(c)The following guidelines¹² can be used to establish criteria for good practices:

(1)eligibility criteria:

(i)have a clear description of the context;

(ii)have a clear description of the objectives and purposes;

(iii)have a clear description of the actions/activities involved;

(iv)are at least one year old;

(2)selection criteria:

(i)are relevant to the needs identified;

(ii)provide sufficient indication of transferability, for example:

(A)continuing after the initial phase;

(B)attracting structural funding or support from new sponsors or leading to the generation of resources;

(C)showing potential for replication in different contexts and application to different target groups.

(d)It is recommended that human factors be reflected in industry standards and good practices when applicable.

Regulation (EU) 2025/23

(a)The competent authority responsible for the oversight of an organisation providing ground handling services at aerodromes in that authority’s Member State shall ensure that all the following aspects are verified during an oversight cycle:

(1)compliance with Annex I to Delegated Regulation (EU) 2025/20:

(i)the organisation’s management system including the organisational structure, processes, programmes and procedures applicable to the ground handling organisation as a whole;

(ii)safety policies and processes, safety management system, including hazard identification, risk assessment and mitigation, including mitigation of safety risks specific to the operational context at the aerodrome(s) subject to oversight;

(iii)the safety and occurrence reporting process and the reports related to the station(s) subject to oversight;

(iv)the management of changes referred to in ORGH.GEN.130 of Annex I to Delegated Regulation (EU) 2025/20 and the declaration;

(v)the compliance monitoring function;

(vi)the record-keeping and documentation system, including the ground handling manual;

(vii)the ground handling training programmes, including the training records;

(viii)the ground support equipment (GSE) maintenance programme;

(ix)any other overarching organisational processes, programmes and procedures within the scope of the ground handling organisation’s declaration and applicable to that organisation as a whole;

(2)compliance with the operational requirements of Annex II to Delegated Regulation
(EU) 2025/20.

(b)When overseeing an organisation providing ground handling services in more than one Member State, the provisions of point ARGH.OVS.330 shall apply.

ED Decision 2025/006/R

MANAGEMENT SYSTEM ASSESSMENT

(a)As part of the oversight tasks, the competent authority should assess the organisation’s management system and processes to make sure that all the required enablers of a functioning management system are present and suitable.

(b)When significant changes take place in the organisation, the competent authority should determine whether there is a need to review the existing assessment to ensure that it is still appropriate.

ED Decision 2025/006/R

ASSESSING THE MATURITY OF THE MANAGEMENT SYSTEM OF A GH ORGANISATION

EASA’s Management System Assessment Tool may be used by both competent authorities and GH organisations to monitor and evaluate the level of maturity of a GH organisation. The maturity level of a GH organisation is expected to increase gradually.

Regulation (EU) 2025/23

(a)Upon receiving a declaration from a ground handling organisation, the competent authority shall acknowledge the receipt of the declaration or the notification of change, including the assignment of an individual reference number, and shall verify that it contains all the information required by point ORGH.DEC.100 and, for the notification of changes, point ORGH.GEN.130 of Annex I to Delegated Regulation (EU) 2025/20. The competent authority shall ensure that the declaration is transmitted to the Repository of Information, in accordance with the terms and conditions of Commission Implementing Regulation (EU) 2023/2117¹³.

(b)If the declaration is not duly filled in or contains information that is not in accordance with
point ORGH.DEC.100 and the Appendix to Subpart ORGH.DEC of Annex I to Delegated Regulation (EU) 2025/20, the competent authority shall notify the ground handling organisation about the missing or incorrect elements and request further information. If deemed necessary, the competent authority shall carry out an inspection of the ground handling organisation. If the non-compliance is confirmed, the competent authority shall take action as defined in point ARGH.OVS.325.

(c)If the declaration contains information that the ground handling organisation provides or intends to provide services also at aerodromes in other Member States, the competent authority receiving the declaration or the notification of change shall ensure all the other competent authorities concerned are informed and have access to the declaration, the notification of change, and all related documentation.

ED Decision 2025/006/R

ACKNOWLEDGEMENT OF RECEIPT

Unless otherwise provided for by the electronic system used to register declarations, the competent authority should acknowledge receipt of the declaration — for example, in writing, preferably by email — within 10 to 15 working days.

ED Decision 2025/006/R

VERIFICATION OF DECLARATIONS

The verification of a declaration received from a GH organisation does not involve the verification of the GH organisation’s documents associated with that declaration. The aim is to check whether the declaration has been correctly filled in and signed, that there is no missing information, etc.

Regulation (EU) 2025/23

(a)The competent authority shall have a system to analyse findings to determine their safety significance and to manage them with the purpose of:

(1)ensuring that compliance with Delegated Regulation (EU) 2025/20 is established as soon as possible;

(2)preventing their reoccurrence.

(b)The competent authority shall issue a level 1 finding where it detects any significant
non-compliance with Delegated Regulation (EU) 2025/20 or of the declaration submitted, which lowers flight or ground safety or seriously jeopardises it.

The level 1 findings shall include, in particular, the following:

(1)any failure to grant access of the competent authority to the facilities of the ground handling organisation pursuant to point ORGH.GEN.140 of Annex I to Delegated Regulation (EU) 2025/20 during normal operating hours and after two written requests;

(2)any evidence of malpractice or fraudulent use of the declaration;

(3)the lack of an accountable manager.

(c)The competent authority shall issue a level 2 finding where it detects any non-compliance with Delegated Regulation (EU) 2025/20 or of the declaration submitted, which is not classified as a level 1 finding and which could lower flight or ground safety or possibly jeopardise it.

(d)Where the competent authority, during investigation or oversight or by any other means, finds evidence that the ground handling organisation does not comply with Delegated Regulation (EU) 2025/20 or the declaration submitted in accordance with point ORGH.DEC.100 of that Regulation, the competent authority shall:

(1)raise a finding, record it, communicate it in writing to the representative of the ground handling organisation, and determine a reasonable period of time within which the organisation shall take the measures specified in point ORGH.GEN.150 of Annex I to Delegated Regulation (EU) 2025/20;

(2)in case of level 1 findings, if the ground handling organisation fails to submit an acceptable corrective action in accordance with point ORGH.GEN.150 of Annex I to Delegated Regulation (EU) 2025/20, take immediate and appropriate action to limit or prohibit the ground handling activities affected by the non-compliance until it has taken the corrective action referred to in point (1); the competent authorities involved in the oversight of the organisation shall assess whether failure to close a level 1 finding by one competent authority affects operation at the aerodromes under their oversight and shall take the appropriate action based on that assessment;

(3)in case of level 2 findings:

(i)request that the organisation provides a corrective-action plan including an implementation period appropriate to the nature of the finding which, in any case, shall initially be no longer than 3 months; at the end of the period and subject to the nature of the finding, the competent authority may extend the initial period subject to a satisfactory revision by the organisation of the initial corrective-action plan with which it had agreed;

(ii)assess the corrective-action plan proposed by the organisation and, if the assessment concludes that it is sufficient to address the non-compliance(s), accept it.

If the ground handling organisation fails to submit an acceptable corrective-action plan or to perform the corrective-action plan within the time period accepted or extended by the competent authority, the competent authority may escalate the level 2 finding to a level 1 finding, and take action as laid down in point (2);

(4)in applying the actions listed in points (2) and (3), coordinate with the other competent authorities concerned, as necessary, to ensure that the continuity of operation and provision of ground handling services at that aerodrome are not impeded;

(5)take any further enforcement measures necessary to ensure the closing of the
non-compliance and, where relevant, remedy its consequences;

(6)record all findings it has raised and, where applicable, the enforcement measures it has applied as specified in Article 62(2) points (d) and (e), of Regulation (EU) 2018/1139, as well as all corrective actions and date of action closure of findings.

(e)The competent authority shall inform the aerodrome operator concerned of the findings relating to the ground handling organisation if those are relevant for the safety of that aerodrome.

(f)For cases not requiring level 1 or level 2 findings, the competent authority may issue observations.

ED Decision 2025/006/R

MANAGEMENT OF FINDINGS

(a)To ensure that the identified areas of non-compliance are adequately addressed by the GH organisation, the competent authority should:

(1)review the root cause(s) identified by the organisation for each confirmed finding, together with the corrective action plan;

(2)be satisfied that the root cause(s) identified and the corrective actions proposed by the GH organisation are adequate to correct the non-compliance and prevent recurrence;

(3)assess the implementation of the accepted corrective actions;

(4)be satisfied that the accepted corrective actions have been adequately implemented;

(5)conclude the findings only after the actions in points (1) to (4) have been completed; and

(6)record all findings and observations.

(b)In the case of level 2 findings, the competent authority should first grant the GH organisation a period to submit a corrective action plan including the root cause(s). This period should be shorter than the corrective action implementation period, to provide sufficient time for the authority to agree on an acceptable corrective action plan and for the GH organisation to implement it before the end of the implementation period.

(c)The competent authority should monitor all due dates agreed in accordance with points (a) and (b).

Regulation (EU) 2025/23

(a)The competent authorities responsible for the oversight of organisations providing ground handling services in more than one Member State or at aerodromes that are under the oversight responsibility of more than one competent authority shall cooperate to ensure effective and efficient oversight of those organisations and their services. Those competent authorities shall ensure mutual exchange of information and assistance to complete their oversight tasks and responsibilities.

(b)The cooperative oversight shall cover the following organisations having their principal place of business in a Member State and providing ground handling services in more than one Member State or at aerodromes that are under the oversight responsibility of more than one competent authority:

(1)independent providers of ground handling services;

(2)self-handling aircraft operators that may or may not be part of a single air carrier business grouping.

(c)The mutual exchange of information shall cover the following elements:

(1)declarations of ground handling organisations and related documents to prove compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts;

(2)AltMoC used;

(3)audit reports, findings raised, corrective actions, corrective-action plans, root-cause analyses, and any other information on the relevant findings raised, follow-up actions, as well as any enforcement measures taken as a result of oversight;

(4)information stemming from mandatory and voluntary occurrence reporting as required by point ORGH.GEN.160 of Annex I to Delegated Regulation (EU) 2025/20.

(d)The tasks for the oversight of a ground handling organisation referred to in point (b) shall be assigned in accordance with points (e) and (f).

(e)The competent authority of the Member State where the organisation has its principal place of business shall verify all the following elements listed in Annexes I and II to Delegated Regulation (EU) 2025/20, either on its own or supported by any of the other competent authorities concerned, followed by inspections of ground handling activities performed at aerodromes in its State, to verify that the implementation of the organisation’s management system elements is performed as documented:

(1)the organisation’s management system elements referred to in point ORGH.MGM.200 of Annex I to Delegated Regulation (EU) 2025/20 relating to the organisational structure, processes, programmes and procedures applicable to the ground handling organisation as a whole;

(2)safety policies and processes, safety management system, including hazard identification, risk assessment and mitigation, including mitigation of safety risks specific to the operational context at the aerodrome(s) subject to oversight;

(3)the safety and occurrence reporting process and the reports related to the provision of ground handling services at the aerodrome(s) subject to oversight;

(4)the management of changes and the declaration;

(5)the compliance monitoring function;

(6)the record-keeping and documentation system, including the ground handling manual;

(7)the ground handling training programmes, including the training records;

(8)the GSE maintenance programme;

(9)any other overarching organisational processes, programmes and procedures within the scope of its declaration and applicable to the organisation as a whole.

(f)Each competent authority of the Member States where the organisation provides ground handling services, other than the Member State where its principal place of business is located, shall oversee the safe provision of services at the stations in their Member State, by verifying the actual implementation of:

(1)the organisation’s management system elements referred to in point ORGH.MGM.200 of Annex I to Delegated Regulation (EU) 2025/20, particularly relating to the ground handling organisation’s activities at the station under its oversight:

(i)the organisational structure referred to in point ORGH.MGM.200(b)(1) of Annex I to Delegated Regulation (EU) 2025/20 and the ground handling activities;

(ii)hazard identification;

(iii)the risk assessment and mitigation, including mitigation of safety risks specific to the provision of services at the station(s) subject to oversight;

(iv)the content of the ground handling manual, including the procedures and instructions of the aircraft operators operating at the station(s) subject to oversight, as well as the procedures of the relevant aerodrome operator(s);

(v)training records and implementation of the training programme at the station(s) subject to oversight;

(vi)the GSE maintenance programme;

(vii)occurrence reports and internal safety reports relevant for the provision of ground handling services at the station(s) subject to oversight;

(2)the operational requirements of Annex II to Delegated Regulation (EU) 2025/20.

(g)Each of the competent authorities referred to in points (e) and (f) shall:

(1)agree with the ground handling organisation on the proposed corrective-action plan and corrective actions to address the non-compliances identified at the station under their oversight;

(2)inform all the other competent authorities concerned on the audits and inspections reports and the corrective actions.

(3)In case of a level 1 finding raised to an organisation referred to in point (b), the competent authority raising the finding shall immediately inform the other competent authorities concerned. Each of the competent authorities responsible for the oversight of that organisation shall assess whether and to what extent the finding affects the stations under its oversight. Each competent authority shall apply the most appropriate action it considers necessary to ensure, as the case may be, the closing of the non-compliance and remedy its consequences.

(4)In case of a level 1 finding raised on the lack of an accountable manager, the competent authority raising the finding shall immediately inform the other competent authorities concerned and they shall all apply the same action uniformly at all the stations under their oversight. They shall take any further enforcement measure necessary to ensure the closing of the non-compliance and remedy its consequences.

(h)All the competent authorities involved in the oversight of an organisation referred to in
point (b) shall support the competent authority of the organisation’s principal place of business to periodically update the assessment of the safety performance of the organisation based on the oversight reports from individual stations in the other Member States.

(i)Any of the competent authorities responsible for the oversight of an organisation referred to in point (b) may support the competent authority of the Member State where the organisation has its principal place of business in performing the audits or inspections as specified in
point (e).

(j)The competent authorities concerned shall establish procedures for the implementation of the cooperative oversight process to cover all the aspects detailed in points (a) to (i).

(k)The competent authorities shall use the repository of information established in accordance with Article 74 of Regulation (EU) 2018/1139 to access the documents and information referred to in point (c).

ED Decision 2025/006/R

MORE THAN ONE COMPETENT AUTHORITY RESPONSIBLE FOR GH OVERSIGHT IN THE SAME MEMBER STATE

Where an organisation referred to in point ARGH.OVS.330(b) provides GH services at aerodromes that are under the oversight of more than one competent authority within the same Member State, it is recommended that that Member State designate the competent authority of the Member State where the organisation has its PPoB for the purpose of establishing clear responsibilities as referred to in point ARGH.OVS.330(d).

ED Decision 2025/006/R

SHARING INFORMATION RELATED TO ALTERNATIVE MEANS OF COMPLIANCE

(a)If an AltMoC submitted by a GH organisation that is part of a single GH business grouping or a single air carrier business grouping for self-handling is applicable only to certain aerodromes, the competent authority receiving the AltMoC should ensure that all the competent authorities concerned have access to it.

(b)The competent authorities of the aerodromes where that AltMoC applies should cooperate to ensure that the content of the AltMoC is accepted and assessed consistently at all the aerodromes where it applies.

ED Decision 2025/006/R

SYSTEMIC AND OPERATIONAL NON-COMPLIANCE

(a)A systemic non-compliance is understood as a non-compliance related to the main components of a GH organisation’s management system, such as:

(1)the SMS,

(2)the compliance monitoring process,

(3)the documentation system,

(4)the training programme,

(5)the GSE operation and maintenance programme,

(6)the general approach to operational procedures.

(b)A systemic non-compliance does not refer to:

(1)operational procedures specific to an aerodrome as required by the aerodrome operator;

(2)safety risk assessment and risk mitigation measures developed for the operational context of an aerodrome.

(c)By comparison, an operational non-compliance is specific to an individual station, as it is related to the way in which the management system or operational requirements are implemented at that aerodrome. This type of non-compliance is, by default, non-systemic — that is, it does not occur at other stations where that GH organisation provides services. An operational
non-compliance does not require action on the part of another competent authority in another Member State.

ED Decision 2025/006/R

COOPERATIVE OVERSIGHT RESPONSIBILITIES IN THE CASE OF SYSTEMIC NON-COMPLIANCE (LEVEL 2 FINDINGS)

(a)If a systemic non-compliance of a GH organisation providing services in more than one Member State is not addressed at the management system level, it may cascade down to all the individual stations, thus generating findings at all stations where the organisation provides GH services. That is why a systemic non-compliance requires enhanced communication and cooperation between all the competent authorities overseeing that GH organisation: it is essential that they all apply similar corrective actions to address that non-compliance in the same manner at the affected stations under their oversight.

(b)When the competent authority of the Member State in which the organisation has its PPoB raises a finding on a management system component, it can already be considered potential systemic non-compliance. The other competent authorities concerned will use this information when preparing their own audits/inspections of stations in their Member State. Each competent authority is responsible for verifying that the systemic non-compliance has been addressed at the individual stations in its Member State.

(c)If a level 2 finding is raised by any competent authority other than that of the Member State in which the organisation has its PPoB, the systemic or operational nature of that non-compliance can only be determined once another audit/inspection in another Member State confirms it. As the information from all audits and inspections is shared among the competent authorities involved in the oversight of that organisation, they will all be aware of the systemic findings. As in the situation described in point (b), the other competent authorities concerned will use this information when preparing their own audits/inspections in their Member State. Each competent authority is responsible for verifying that the systemic non-compliance has been addressed at the individual stations in its Member State.

(d)The information related to systemic non-compliance can be useful for assessing the safety performance of the organisation as a whole.

ED Decision 2025/006/R

COOPERATIVE OVERSIGHT ACTIONS

The competent authorities concerned could consider any of the examples provided below to ensure continuing communication and consultation among themselves to establish efficient cooperative oversight.

(a)Develop a common toolbox of materials and checklists to be used when conducting inspections and audits.

(b)Establish procedures to cover methods and timing for communicating on and sharing of relevant information necessary for oversight, for example:

(1)sharing the result of the assessment of a management system every time an assessment is conducted by one of the competent authorities;

(2)sharing the AltMoC as soon as they are received by the competent authority of the Member State in which the organisation has its PPoB;

(3)ensuring a prompt reaction if one of the competent authorities shares serious concerns about the organisation with another competent authority.

(c)Develop a common training programme and deliver training sessions for all GH inspectors.

(d)Organise joint inspections and audits.

(e)Discuss the findings raised, their legal basis and the corrective actions proposed by the organisation. Identify the best way forward for similar cases.

(f)Organise recurrent training sessions that include the sharing of experiences with competent authorities in other Member States and exchange of best practices with inspectors from other competent authorities.

(g)Additional support could include the translation of relevant parts of audit reports or of occurrence reports from the original language into English or any other language upon which the competent authorities concerned agree.